Professional Summary

Eric D. Swenson is the Leader of the Firm’s Tax team. Eric’s practice focuses on tax controversy and business transactions.  As a former IRS attorney Eric represents corporations, partnerships, nonprofits and individuals in federal, state and local tax disputes including audits, appeals and litigation before several tax agencies. He has extensive experience structuring and planning corporate mergers and acquisitions including tax-free organizations, choice of entity, debt and equity restructuring, litigation settlements, employment and executive compensation. Eric is admitted to practice in the U.S. Tax Court, U.S. Court of Federal Claims and the U.S. District Court, Southern District of California.

Eric is a member of Procopio’s COVID-19 Legal Resources Team.


  • The Best Lawyers in America® 2021-present (Litigation & Controversy: Tax)
  • 2019 West Coast Top Rated Lawyers, ALM
  • V. Judson Klein Award for Tax Excellence 2014
  • "Top Lawyers,” San Diego Magazine, 2013-Present
  • Martindale-Hubbell® AV Preeminent Rating
  • San Diego Business Journal Best of the Bar 2015
  • Southern California’s Top Rated Lawyers 2012-2015


  • The State Bar of California – Past Chair International Tax Committee, Past Chair Income and Committee, Past Member Taxation Section Executive Committee
  • Pacific Beach Community Foundation – Past Director, Past President
  • San Diego County Bar Association – Past Taxation Section Chair
  • University of San Diego School of Law – Past Adjunct Professor – LLM Program


  • JD, Southern Illinois University School of Law
  • LL.M. (Taxation), University of San Diego School of Law
  • BS (Accounting), Millikin University

News Coverage

  • Amanda Athanasiou. “IRS Official Notes Inappropriate Use of Streamlined Procedures,” Tax Notes Today, November 13, 2020.
  • Natalie Olivo. “Don't Be 'Coy' When Reporting Offshore Info, IRS Official Says,” Law360, November 12, 2020.
  • Hansen, David. "IRS Arbitrarily Calculated $1.5M FBAR Penalty, Court Says," Law260, May 12, 2020.
  • Dan Heching, Gina Kim and Melanie Brisbon. “Exactech acquires XpandOrtho, with help from Procopio,” San Diego Daily Transcript, March 19, 2019.
  • Kristen A. Parillo . “Withholding Tax Liability Is a Partnership Item, Tax Court Rules,” Tax Notes, August 9, 2018.
  • “Sullivan Vineyards & Winery Find New Home at VITE with Procopio’s Counsel,” San Diego Daily Transcript, January 23, 2018.
  • Amanda Athanasiou. “IRS Attorney Responds to OVDP Criticisms,” Tax Notes Today, October 27, 2017.
  • Emily L. Foster. “Gambling Industry wins Big With Final and Proposed Regs,” Tax Notes Today, December 30, 2016.
  • Nathan J. Richman. “New Analysis & Daily Fantasy Sport Tax Reporting Could Use Clarification,” Tax Notes Today, February 3, 2016.
  • “Procopio's Swenson to receive State Bar award for tax practice,” The Daily Transcript, September 16, 2014.


  • Moderator, "U.S. International Investigations of U.S. Financial Accounts: (Summonses, Enablers & Limits on Privilege)," USD Procopio International Tax Institute, November 12, 2020.
  • Moderator, “Remaining Offshore Compliance Options and International Hot Topics,” USD Procopio International Tax Institute, November 1, 2018.
  • Presenter, “Tax Residency, California Tax Domicile, Federal Tax Treaty Rules, and Defending Tax Residency Audits,” California Lawyer’s Association, Taxation Section, October 25, 2018.
  • Moderator.  “Offshore Accounts and Compliance – Where Are We Today?” USD Procopio International Tax Institute, October 26, 2017.
  • Presenter. “The Willfulness Standard and the Offshore Voluntary Disclosure Initiative,” San Diego Internal Tax DG (Cal. Society of CPA’s), June 1, 2017.
  • Moderator. “Tax Court Trials – A U.S. and Mexico Comparison, Tales from the Bench,” USD Procopio International Tax Institute, October 21, 2016.
  • Moderator. “Defending an International Tax Case Before the IRS and SAT,” USD Procopio International Tax Institute, October 20, 2016.
  • Moderator “International Tax Audit & Appeals Including Statute of Limitations in the International Context,” 2015 California Tax Bar and California Tax Policy Conference, November 6, 2015.
  • Moderator “Foreign Targets: IRS International Criminal Investigations: FIFA,” USD Procopio International Tax Institute, October 23, 2015.
  • Co-Presenter. “OVDP and FATCA Update: The Nuts and Bolts of Streamlined Filing and Proving Non-Willfulness,” University of San Diego, School of Law, June 25, 2015
  • “A Dozen Tax Issues Every Business Attorney Must Understand,” Procopio Business and Technology Team, San Diego, CA, December 18, 2014.
  • Moderator. "Recent Developments in International Criminal Tax," USD Procopio International Tax Institute, October 31, 2014.
  • Moderator. "International Tax Audits & International Tax Appeals," USD Procopio International Tax Institute, October 30, 2014.
  • “Money for Lunch Talk Show,” BlogTalkRadio, September 25, 2014.
  • “OVDP and FATCA update: The Ever Changing Issues of International Tax Compliance,” University of San Diego, School of Law, June 26, 2014
  • “How to Survive an Audit or Difficult Tax Controversy; What to Expect When the Tax Authorities Come Knocking,” San Diego CPA Education Association,” May 13, 2014.
  • “Personal Tax Issues and Strategies,” FEI San Diego, San Diego, CA, January 23, 2014.
  • “FATCA, OVDI, and More…,” 17th Annual San Diego Tax and Accounting Institute, San Diego, CA, November 22, 2013.
  • Moderator. “Starting the Race Against the Tax Authority in the International Tax World – Statute of Limitations & Lack of Filings,” USD School of Law-Procopio International Tax Institute, San Diego, CA, October 2013.
  • “2013 Tax Update,” Business Sections of the San Diego County Bar Association, San Diego, CA, July 25, 2013.
  • “Tax Considerations for Small Business Owners,” Filipino American Chamber of Commerce of San Diego County and the Filipino American Lawyers of San Diego: Small Business Legal Symposium, March 9, 2013.